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Anti-corruption and crime prevention

In order to ensure conditions of correctness and transparency in conducting the company’s business activities, CIR has equipped itself with an “Organization, Management and Control Model” in line with the instructions set out in Legislative Decree no 231/2001 on the administrative liability of legal entities.

The Model is subjected periodically to a check as to whether it is adequate and where necessary it is updated in order to guarantee that it continues to be in line with any new legislation that has been introduced and that it is adequate for the organizational structure of the parent.

The Board of Directors Meeting held on July 28 2017 approved the latest version of the “Organization, Management and Control Model” adopted by the company after the update made necessary by the outcome of the  self-assessment carried out at the end of 2016 and the most recent regulatory innovations. As well as the additions made to the catalogue of offences listed in the General Part in 2016, the structure of the new Model has been redefined and is now organized in processes, whereas the previous traditional approach was by type of offence. This has made the new Model easier to consult and has made its implementation more effective.

The Model consists of a “General Part” and four “Special Parts”:
  • Special Part A – Code of Ethics, which gives the Code of Ethics in full;
  • Special Part B – 231 Predicate Crimes and Sensitive Processes, regarding the representation of the crimes as per Legislative decree no 231/2001 deemed relevant for the parent and the Sensitive Processes where there is a risk that the said offences could be committed;
  • Special Part C – Sensitive Processes: principles of conduct and control, a list of the General Principles of conduct applicable to all Sensitive Processes, and for each Sensitive Process, an indication of the essential procedures of the internal control system and the specific principles for conduct aimed at preventing the risk that the crimes contemplated by the Decree could be committed;
  • Special Part D – Market Abuse Offences: principles of conduct and control, which deals specifically with the subject of market abuse.

CIR has appointed a Supervisory Body, made up of two external members and the Head of Internal Audit of the parent, which has responsibility for monitoring the effectiveness and the functioning of the Model and checking that it is complied with and that it is kept constantly updated.

The individual companies of the group have also adopted their own Organization Models, through which they set out clear rules of conduct, control and measuring systems for safeguarding the health and safety in the workplace of their employees, with a view to increasing transparency in the running of the businesses.